Coronavirus Update

Paycheck Protection Program (PPP) – Forgiveness

Updated 10/1/2020

We are starting to get a lot of anxious questions regarding PPP Forgiveness. While we are looking to start the PPP Loan Forgiveness process in October, there is still pending legislation that could substantially reduce the level of supporting documentation required by the SBA. We will contact you via e-mail when the process begins. Some of the earlier PPP loans were to begin repayment in October; however, please note that all loans are subject to the updates from the PPP Flexibility Act, regardless of the loan agreement language.

Per the PPP Flexibility Act and subsequent SBA guidance, as long as a Borrower submits its loan forgiveness application within ten (10) months of the completion of the Covered Period, the Borrower is not required to make any payments until the forgiveness amount is remitted to the Lender by SBA. If the loan is fully forgiven, the Borrower is not responsible for any payments. If only a portion of the loan is forgiven, or if the forgiveness application is denied, any remaining balance due on the loan must be repaid by the Borrower on or before the maturity date of the loan. Interest accrues during the time between the disbursement of the loan and SBA remittance of the forgiveness amount. The Borrower is responsible for paying the accrued interest on any amount of the loan that is not forgiven. As a reminder, the PPP Flexibility Act allows the Borrower to extend its Covered Period from 8 weeks to the earlier of December 31, 2020, or 24 weeks from the date of the loan.

Based on the PPP Flexibility Act and subsequent guidance, we do not anticipate that PPP Borrowers will need to make payments in October and November so long as they timely submit a forgiveness application, when we are ready to accept them.

We know many of you are anxious to start this process, and we are too. However, we believe that waiting a bit longer to take applications will allow us to refine our planned process and incorporate the ever-changing guidance and interpretations issued by the SBA. Taking the time to do this right will benefit everyone. In addition, we are keenly monitoring the proposed legislation to grant expedited or automatic forgiveness of small PPP loans under $150,000 and although the likelihood of legislative consensus appears to be decreasing, it is possible that this proposed legislation may come to fruition.

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